On Thu, 24 Feb 2005 14:08:47 -0500, Terry Schofield <[log in to unmask]> wrote:
> We are not subject to Sarbanes-Oxley; however, we took the position that we
> would be Sarbanes-Oxley compliant since many of our member companies are.  I
> will add that to my list of arguments.  Thank you, Ginny.
>

You may not be subject to S-Ox but as an RTO (regional transmission
organization) wouldn't you be subject to FERC regulations?

http://www.ferc.gov/industries/electric/indus-act/rto.asp

Your organization's first step is to establish a policy concerning the
use of IM within the company. This can be as simple as "PJM does not
allow the use of IM for business purposes" from that you can develop
guidelines and rules as well as the consequences for violating the
policy. As others have noted IM can be a record and if used for
business purposes it must be captured and retained.

Peterk

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